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Medicare telehealth waivers and billing during COVID-19 PHE

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Explains CMS waivers and FAQs allowing expanded Medicare telehealth coverage and billing flexibilities during the COVID-19 public health emergency, affecting Medicare beneficiaries and qualified providers nationwide.

Policy Summary

Payerimperialinsurancecompanyofutah

PolicyMedicare telehealth waivers and billing during COVID-19 PHE

Policy CodePolicy N/A

Change TypeWaiver and enforcement discretion

Effective DateMar 6, 2020

Last ReviewMar 17, 2020

Next Review DateN/A

Key ActionRemove originating site restrictions so beneficiaries in all areas, including their homes, may receive telehealth services during the PHE.

SourceLink

POLICY UPDATE CHANGES

The Secretary may waive Medicare telehealth originating site restrictions to allow beneficiaries in all areas and in their homes to receive telehealth services during the COVID-19 PHE.

HHS will exercise enforcement discretion and not audit for a prior established patient relationship for telehealth claims submitted during the PHE.

HHS OCR will exercise enforcement discretion regarding HIPAA penalties for good-faith use of everyday communications technologies (e.g., FaceTime, Skype) during the PHE.

2020-03-06waiver start

Nationwideoriginating site

Samepayment parity

02POS code

Q3014facility fee code

Medicare Telehealth Coverage During COVID-19 PHE

Medicare telehealth coverage during COVID-19 PHE

Coverage expanded under the Section 1135 waiver during the PHE with specified limitations and requirements.

ALL of the following

ALL of the following
- Originating site restrictions waived so beneficiaries in all areas, including their homes, may receive telehealth services during the PHE.
ALL of the following
- Services described by the CMS telehealth list and other professional services commonly furnished remotely may be provided via telehealth, provided they remain reasonable and necessary under section 1862(a) of the Act.
ALL of the following
- Physicians and certain non-physician practitioners (e.g., nurse practitioners, physician assistants, certified nurse midwives) and other practitioners within their Medicare scope may furnish telehealth services; the waiver does not change practitioner scope-of-practice rules.
ALL of the following
- Billing for telehealth professional services is limited to professionals; originating sites (e.g., hospitals, nursing homes) may bill for a facility fee where applicable (for example, Q3014).
ALL of the following
- Medicare payment rules apply; telehealth services are reimbursed consistent with Medicare requirements (payment parity and beneficiary cost-sharing remain unless otherwise modified by guidance).
ALL of the following
- Waiver effective for services starting March 6, 2020 and remains in effect until the HHS-declared Public Health Emergency ends.
ALL of the following
- Two-way, real-time audio/video technology is acceptable for telehealth; HHS OCR indicated enforcement discretion for good-faith use of common communications technologies during the emergency.
ALL of the following
- Telehealth flexibilities apply regardless of patient diagnosis and are not limited to COVID-19-related care.

ALL of the following

Providers must continue to ensure services meet Medicare's reasonable and necessary standard (section 1862(a)).

Billing Codes, Modifiers, and Payment

Telehealth place of serviceHCPCS | Modifier

02	Place of Service code for telehealth

Originating site facility feeHCPCS | Modifier

Q3014

Originating site facility fee

Asynchronous telehealth modifierHCPCS | Modifier

GQ	Asynchronous telehealth for federal demonstration (Alaska/Hawaii)

CAH telehealth modifierHCPCS | Modifier

GT	CAH Method II telehealth

Acute stroke telehealth modifierHCPCS | Modifier

G0	Telehealth for acute stroke diagnosis and treatment

inv-03: Payment parity — Medicare pays same as in-person; facility rate used when office vs facility differential exists.

Medicare payment parityMedicare pays the same amount for telehealth services as if furnished in person; when an office vs facility payment differential exists, Medicare uses the facility payment rate for telehealth.

Beneficiary cost sharingBeneficiaries remain liable for deductible and coinsurance unless waived by other authority (OIG flexibility noted elsewhere).

Applies to services on PFS listPayment parity applies to services described by HCPCS codes paid under the Physician Fee Schedule that are furnished via telehealth.

Provider Obligations and Enforcement Discretion

Denial Risk

No audits of prior established relationship during PHE

HHS announced enforcement discretion and will not audit claims to verify a prior established patient relationship for telehealth services furnished during the COVID-19 public health emergency.

Billing Rule

Originating site restrictions waived — home and all areas allowed

The Section 1135 waiver removes originating site restrictions so beneficiaries in all areas of the country, including those in their homes, may receive Medicare telehealth services effective for services starting March 6, 2020 and lasting for the duration of the PHE.

Waiver effective for services beginning March 6, 2020.
Originating site expansion includes patients outside rural areas and patients in their homes.

Documentation Required

HIPAA enforcement discretion for use of everyday telehealth technologies

HHS Office for Civil Rights will exercise enforcement discretion and waive penalties for HIPAA violations when providers, in good faith, use everyday communications technologies (e.g., FaceTime, Skype) to furnish telehealth services during the COVID-19 PHE.

Two-way, real-time audio/video technologies are acceptable; phones with audio/video capabilities qualify.
Good‑faith use of common apps will not be subject to OCR penalties for the duration of the emergency.

Key Terms

inv-07: eligible originating site — Definition and note about originating site (historical limits and PHE waiver to include home).

Definition - Originating siteLocation where the beneficiary receives telehealth services; historically limited to certain facilities and rural areas.

PHE waiver effective March 6, 2020Section 1135 waiver temporarily eliminates the originating site restriction, allowing beneficiaries to receive telehealth services in all settings, including their homes, for the duration of the PHE.

Scope of changeWaiver permits telehealth services to be provided in any setting of care, not limited to medical facilities or rural areas.

inv-08: Qualified providers — physicians and certain non-physician practitioners (e.g., NPs, PAs, CNMs) and other practitioners within their Medicare scope who may furnish telehealth services.

Qualified provider typesPhysicians and certain non-physician practitioners such as nurse practitioners (NPs), physician assistants (PAs), and certified nurse midwives (CNMs).

Other practitioners within scopeOther practitioners (e.g., certified nurse anesthetists, licensed clinical social workers, clinical psychologists, registered dietitians/nutrition professionals) may furnish telehealth services within their Medicare scope and consistent with benefit rules.

Waiver does not change scope rulesThe waiver does not alter practitioner scope-of-practice requirements; providers may only bill for services they are authorized to furnish under Medicare rules.

Policy Summary

Payerimperialinsurancecompanyofutah

PolicyMedicare telehealth waivers and billing during COVID-19 PHE

Policy CodePolicy N/A

Change TypeWaiver and enforcement discretion

Effective DateMar 6, 2020

Last ReviewMar 17, 2020

Next Review DateN/A

Key ActionRemove originating site restrictions so beneficiaries in all areas, including their homes, may receive telehealth services during the PHE.

SourceLink

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Medicare telehealth waivers and billing during COVID-19 PHE

Customize your policy alerts

Sign up for all imperialinsurancecompanyofutah policy alerts

Know when imperialinsurancecompanyofutah releases new policies or updates existing guidance.

Monitor payer policy activity

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Medicare Telehealth Coverage During COVID-19 PHE

Medicare telehealth coverage during COVID-19 PHE

Coverage expanded under the Section 1135 waiver during the PHE with specified limitations and requirements.

ALL of the following

ALL of the following
- Originating site restrictions waived so beneficiaries in all areas, including their homes, may receive telehealth services during the PHE.
ALL of the following
- Services described by the CMS telehealth list and other professional services commonly furnished remotely may be provided via telehealth, provided they remain reasonable and necessary under section 1862(a) of the Act.
ALL of the following
- Physicians and certain non-physician practitioners (e.g., nurse practitioners, physician assistants, certified nurse midwives) and other practitioners within their Medicare scope may furnish telehealth services; the waiver does not change practitioner scope-of-practice rules.
ALL of the following
- Billing for telehealth professional services is limited to professionals; originating sites (e.g., hospitals, nursing homes) may bill for a facility fee where applicable (for example, Q3014).
ALL of the following
- Medicare payment rules apply; telehealth services are reimbursed consistent with Medicare requirements (payment parity and beneficiary cost-sharing remain unless otherwise modified by guidance).
ALL of the following
- Waiver effective for services starting March 6, 2020 and remains in effect until the HHS-declared Public Health Emergency ends.
ALL of the following
- Two-way, real-time audio/video technology is acceptable for telehealth; HHS OCR indicated enforcement discretion for good-faith use of common communications technologies during the emergency.
ALL of the following
- Telehealth flexibilities apply regardless of patient diagnosis and are not limited to COVID-19-related care.

ALL of the following

Providers must continue to ensure services meet Medicare's reasonable and necessary standard (section 1862(a)).

Billing Codes, Modifiers, and Payment

Telehealth place of serviceHCPCS | Modifier

02	Place of Service code for telehealth

Originating site facility feeHCPCS | Modifier

Q3014

Originating site facility fee

Asynchronous telehealth modifierHCPCS | Modifier

GQ	Asynchronous telehealth for federal demonstration (Alaska/Hawaii)

CAH telehealth modifierHCPCS | Modifier

GT	CAH Method II telehealth

Acute stroke telehealth modifierHCPCS | Modifier

G0	Telehealth for acute stroke diagnosis and treatment

inv-03: Payment parity — Medicare pays same as in-person; facility rate used when office vs facility differential exists.

Beneficiary cost sharingBeneficiaries remain liable for deductible and coinsurance unless waived by other authority (OIG flexibility noted elsewhere).

Applies to services on PFS listPayment parity applies to services described by HCPCS codes paid under the Physician Fee Schedule that are furnished via telehealth.

Provider Obligations and Enforcement Discretion

Denial Risk

No audits of prior established relationship during PHE

HHS announced enforcement discretion and will not audit claims to verify a prior established patient relationship for telehealth services furnished during the COVID-19 public health emergency.

Billing Rule

Originating site restrictions waived — home and all areas allowed

Waiver effective for services beginning March 6, 2020.
Originating site expansion includes patients outside rural areas and patients in their homes.

Documentation Required

HIPAA enforcement discretion for use of everyday telehealth technologies

Two-way, real-time audio/video technologies are acceptable; phones with audio/video capabilities qualify.
Good‑faith use of common apps will not be subject to OCR penalties for the duration of the emergency.

Key Terms

inv-07: eligible originating site — Definition and note about originating site (historical limits and PHE waiver to include home).

Definition - Originating siteLocation where the beneficiary receives telehealth services; historically limited to certain facilities and rural areas.

Scope of changeWaiver permits telehealth services to be provided in any setting of care, not limited to medical facilities or rural areas.

inv-08: Qualified providers — physicians and certain non-physician practitioners (e.g., NPs, PAs, CNMs) and other practitioners within their Medicare scope who may furnish telehealth services.

Qualified provider typesPhysicians and certain non-physician practitioners such as nurse practitioners (NPs), physician assistants (PAs), and certified nurse midwives (CNMs).

Waiver does not change scope rulesThe waiver does not alter practitioner scope-of-practice requirements; providers may only bill for services they are authorized to furnish under Medicare rules.